Always wrong, never in doubt. IRS Struggles With REMIC Relief

see https://www.jdsupra.com/legalnews/irs-extends-remic-and-trust-relief-9911184/

Always wrong, never in doubt.

The problem is not whether REMIC trusts, trustees, and beneficiaries should be given extensions on reporting and other relief on the cash flow generated or delayed through REMICs.

The problem is that there is no cash flow through REMIC trusts. There is no real estate. There is no mortgage. There is no investment. And nothing flows through the REMIC as a conduit. The beneficiaries are not investors who bought certificates. The underwriters and beneficiaries are both the same entity: the investment bank bookrunner. And the named “trustee” neither knows nor manages any assets.

So much for Real Estate Mortgage Investment Conduit.

There is nothing to extend except the illusion that these REMICS exist. There is no relief because there is nothing to tax — except for the unreported revenue of the investment bank.

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